SOCIAL AND COMMUNITY DEVELOPMENT OF THE AHAFO REGION COLLABORATION TO PROMOTE PROJECT BENEFITS VISION AND COMMITMENTS AHAFO GOLD PROJECT

Transcription

1 SOCIAL AND COMMUNITY DEVELOPMENT OF THE AHAFO REGION COLLABORATION TO PROMOTE PROJECT BENEFITS VISION AND COMMITMENTS AHAFO GOLD PROJECT Prepared by: Newmont Ghana Gold Ltd. C825/26 Lagos Avenue East Legon, Accra, GHANA Prepared for: International Finance Corporation 2121 Pennsylvania Ave., NW, Room No. F-9K-198 Washington D.C USA October 2005

2 TABLE OF CONTENTS INTRODUCTION...1 PROJECT IMPACT MITICATION...2 Project Affected People...2 Livelihood Enhancement and Community Empowerment Program Phase SUSTAINABLE COMMUNITY DEVELOPMENT...6 Objective Assessment and Performance Evaluation...6 Human Rights...6 Sustainable Development Foundation...6 Leveraging Knowledge, Expertise and Collaborative Association...7 LIVELIHOOD ENHANCEMENT AND COMMUNITY EMPOWERMENT PROGRAM PHASE Agriculture Development...7 Small-and-Medium Enterprises...7 Water Sanitation...8 Employment and Training...8 Community Health...9 Public Consultation...9 CULTURAL HERITAGE RESOURCES...11 ENVIRONMENTAL MANAGEMENT AND CLOSURE PLANNING...11 MONITORING...12 RESOURCES...13 Table 1 Table 2 Summary of Project-Affected People Commitments Summary of Broader Community commitments and Benefits

3 Social and Community Development 1 INTRODUCTION Economic activity and its inherent contributors and benefactors are vital components of Ghana s development trajectory aimed at poverty reduction. The extractive sector plays a vital role as a fundamental economic building block from which a diverse set of business activities can be derived. Similarly, the extractive sector is part of the overall strategic development plan of Ghana on a broader scale to increase revenues and the inherent development benefits associated with sector development and modernization. At the same time, the extractive sector has seen recent pressure from communities and civil society to assume even greater responsibilities for revenue generation and distribution, transparency, capacity building and development initiatives. These responsibilities, when coupled with those of government and civil society, become powerful drivers and lead to important partnerships. Newmont Mining Corporation, with its recent move into Africa, and along with its host communities, stakeholders and partners, aspires to demonstrate corporate social responsibility as a promoter and key participant in the creation of sustainable development outcomes in and around our Ahafo project area. To this end, Newmont as a global company, is committed to respecting the Universal Declaration of Human Rights, the World Bank Safeguard Policies and the Equator Principles in its business operations. We are committed to the UN s Global Compact, the Voluntary Principles on Security and Human Rights, the Extractive Industries Transparency Initiative, Publish What You Pay, the World Economic Forum s Partnering Against Corruption Initiative, the Sullivan Principles and the International Council on Mining & Metals Sustainability Principles. The company uses internationally-recognized standards - such as the Institute of Social and Ethical Accountabilities standard on stakeholder engagement (AA 1000) to guide the formation of its policies and standards. The company reports, in addition, in accordance with the requirements of the Global Reporting Initiative. Specifically for the Ahafo project, the vision shared between Newmont, local communities and the Ghanaian government is that the people of the Asutifi and Tano districts have an enhanced socio-economic well-being, their health is improved, education and training opportunities increase and accelerate, and that all of these improvements are sustainable, independent of and beyond the life of the mining activity. Overall, the aim is that people will be better off for Newmont being there than not being there. The company commits to develop monitoring methods to track this statement. The Ahafo Project will essentially be developed in two phases. The first phase is referred to as the Ahafo South Project. The project is located within the Brong Ahafo region of central western Ghana. The project is situated on a mining concession of approximately 720 square kilometers with numerous deposits running north to south. Construction of the Ahafo South portion began in April Mining is expected to start early in 2006, with gold production beginning in mid The present report focuses on and discusses NGGL s social responsibility related to local community impacts and mitigation and the broader sustainable development commitments which will be integral components of the overall Ahafo South project.

4 Social and Community Development 2 PROJECT IMPACT MITIGATION Any new industrial project has impacts both on the physical and the social context. This is especially the case when the project is in a rural area of a developing country. These impacts can be both positive and negative. Newmont is committed to mitigating these latter impacts to ensure that there is a net no harm impact on project-affected people, but rather projectaffected people realize some added benefit as a result of the project. The company has produced and disclosed a series of project-related documents which detail the specific environmental and social conditions and associated action plans to mitigate adverse impacts. These documents are presented on the web sites of both the International Finance Corporation (IFC) and Newmont Mining Corporation. Resettlement Action Plan-Ahafo South Project (RAP), Planning Alliance, Environmental Social Impact Assessment (ESIA) -Ahafo South Project, Maxim Technologies Inc., Public Consultation and Disclosure Plan (PCDP)-Ahafo South Project, Maxim Technologies Inc., Newmont Ghana Gold LTD., Ahafo South Project, Independent Assessment of Resettlement Implementation, Frederic Giovannetti, Project Affected People Newmont is committed to those people directly affected by the project (PAP): those whose houses and farm areas have disappeared, or are no longer habitable or workable, because of the mine (9,575 individuals). Overall, the company commitment, as described in the RAP, is to restore and improve the livelihoods and well-being of impacted peoples, households and communities, such that they are equal to or better than before the project s impact. In addition, there will be a focus on particular groups such as youth and women to ensure their access and representation in all aspects of resettlement. The monitoring program to ensure this will begin in the second quarter of Compensation As fully described in the RAP, compensation has been paid to project-affected people according to parameters set by the elected Resettlement Negotiation & Compensation Committee and on the basis of non-coerced, prior and informed consent. People were offered choices between acceptable, fair and equitable alternatives. Compensation included full replacement cost of structures, assistance with moving personal belongings, efforts to improve former living standards and compensation for crops. Land, housing, infrastructure and other compensation were provided to the adversely affected population at a total cost of over $13 million Resettlement The RAP and its implementation were reviewed by an independent assessor, Frederic Giovannetti in August The result is publicly available as mentioned above. The RAP implementation will be reviewed again in December 2005, March 2006 and September 2006 and periodically beyond that.

5 Social and Community Development 3 Apart from building some 399 (RAP, August 2005) houses in two resettlement villages, the company has committed to working with these new communities to ensure better critical facilities than previously was the case. Components of the resettlement village commitments include the formation and training of Water & Sanitation Committees according to the rules and procedures of Ghanaian regulations, erosion monitoring and control, and inventory/repair of building defects during the guarantee period. The objective of these programs are to establish sustainable systems which can be managed by the communities themselves. Vulnerable people Within the resettlement process and among the PAP, in addition to ordinary Ahafo citizens, the company will focus on the most vulnerable and disadvantaged and take special notice of groups often left out of things: women s and youth groups for instance. We commit to strengthening our policy on vulnerable people, which includes clarifying and identifying those people, and developing household vulnerability criteria with community input including the design of monitoring and mitigation measures. The company will monitor and assist vulnerable persons during life of project. Land access The mine area covers 2,426 hectares of farmland. 1,965 hectares of this were actively cropped and were compensated for. Land for land is a major issue for the company and its neighbors and more specifically within the Ghanaian regulatory context. Land shortage and degradation have meant that land access for people was an existent problem in Brong Ahafo. The complex and changing system of land tenure and its control by local traditional authorities brings an added set of problems. The ownership of exterior fallow land (i.e. land outside active crop land parcels) is and always has been problematic for everyone. The legal situation relating to fallow land is in transition and under review. As a result of the project, fallow land is opened by farmers who have lost access to land. Further complication occurs because farmers are initiating crop compensation claims in fallow land to gain access to compensation for the few domesticated plants that survive in the fallow (e.g., cocoyam, cassava, mango, oil palm, teak). There is no mechanism currently in Ghanaian law to allow unused land to be compensated. Ownership is a complex issue with users, traditional authorities, families and the state all having overlapping rights. The company is committed to monitoring and studying fallow land (and the broader issue of access to land) in order to understand the impact of its loss and to support appropriate mitigation measures that are agreeable to traditional authorities and affected farmers. The company clearly recognizes the importance that access to land has for sustainable farming practices and ensuring food security for individuals. The company is committed to development and implementation of a land replacement strategy which will create a land bank to include land inside mining take area and also outside land. NGGL, working with OICI, will facilitate acquisition of land, through established channels, by farmers who need replacement land. The company will monitor land acquisition in twice yearly surveys of landowners and sharecroppers and will track landowners and sharecroppers involved in customary land exchange process.

6 Social and Community Development 4 The company will manage and expand the existing household database to monitor progress of securing replacement land on a household by household basis. A senior officer will be appointed to manage this process. Livelihood Enhancement and Community Empowerment Program Phase 1 The company has defined a number of livelihood enhancement initiatives to help PAP reestablish their livelihoods or create new ones. From the beginning of its activities in Ghana, Newmont has sought to understand the communities way of life and how it may be impacted by the company s activities. An extensive Livelihood Survey, independently undertaken by the NGO, Opportunities Industrialization Centres International (OICI) in September 2003, examined, among other things, the existing socio-economic levels, including literacy and gender statistics and characteristics of communities in the Ahafo concession area. Based on the data from the Livelihood Survey and from intensive consultation and engagement with local stakeholders, a comprehensive and sustainable community development program the Livelihood Enhancement and Community Empowerment Program (LEEP) was developed by OICI on behalf of Newmont Ghana Gold. The program is intended to enhance the livelihood of people in the mine take area (Phase 1) and has been finalized by a community advisory committee, consisting of representatives of the communities, government agencies and NGOs, as well as OICI and Newmont Ghana. The LEEP (Phase 1) program targets households that have been economically displaced by the project and households that are physically displaced and resettled or relocated by the project. LEEP 1 was launched in February 2005 and it is anticipated that it will last 18 months, or until operations commence. The overall cost of LEEP 1 is $715,000. Livelihoods To assess and monitor socio-economic conditions for project affected peoples, NGGL will commission quarterly socio-economic surveys to be conducted by OICI in collaboration with the communities. Newmont s program goal and commitment is to enhance livelihood capacity of an estimated 2,000 households through income generating activities and alternative livelihoods. Money management seminars have been conducted for project affected peoples. NGGL will create and strengthen local small-to-medium-enterprises (SMEs) to benefit around 1500 people. Micro Credit NGGL is developing and implementing a micro-credit scheme for affected people and will provide initial funds to the level of $200,000 for SME development for Agriculture and Food Security Through a variety of means including agricultural development and training projects, NGGL intends to work with partners to improve food and cash crop production for 750 households and reduce post-harvest and storage losses by 5% for 750 households. The focus will be to

7 Social and Community Development 5 improve the agricultural potential of farmers in the Ahafo area to include both Newmontmanaged land and the adjacent farm lands near and around the mine site. Education Newmont is committed to increase the level of education in the project affected area via both infrastructure and capacity building. The company will construct or rehabilitate schools to increase access to quality education, skills training and recreation. A new school has been completed at the Ola, or Kenyase 2, resettlement village. Additional classrooms and staff facilities have also been added to the new school built at Ntotoroso resettlement site. Capacity Building NGGL has enhanced technical and vocational skills for 600 youth for direct employment in the construction phase of the project through a partnership with the Ghana National Vocational & Training Institute and at the Newmont training center at Yamfo (enhanced and refurbished),. The company has also formed community youth support groups, is providing training in participatory decision-making and undertaking capacity-building for groups to support social services. In particular, NGGL strives to improve the technical and organizational capacities of women. Human Capabilities In addition to creating new residences for project-affected peoples, the company has been committed to improve access to basic infrastructure which are fundamental to healthy communities. In particular, NGGL has increased access to potable water and sanitation facilities for 23,000 local people. In addition, the company is working to enhance the capabilities of 2,000 households in health, nutrition and education. TABLE 1 Summary of Project-Affected People Commitments Action Key Benefit/Mitigated Loss Implementation Schedule Project-Affected People Compensation Structures, crop loss, relocation Complete Nov 2005 expenses Project-Affected People Resettlement Living condition/structure Complete Nov 2005 Develop a Land Replacement Strategy Food security, livelihood Initiate by Dec 2005 continuation Monitor Access to Land Food security, Livelihood Bi-annual beginning Livelihood Enhancement and Community Empowerment Program Phase 1 Independent Resettlement/Livelihood monitoring continuation Livelihoods enhancement/replacement, capacity building, micro-credit, food security, Small and Medium Size Enterprises Ensure program effectiveness and redress issues January 2006 Initiated Feb 2005 Initiate Aug 2005; quarterly for 1 year; periodically Life of Mine

8 Social and Community Development 6 SUSTAINABLE COMMUNITY DEVELOPMENT In addition to mitigation for the project-affected people, NGGL is committed to a positive impact on the broader local community. Objective Assessment and Performance Evaluation In September 2005, an independent NGO Collaborative for Development Action completed an independent baseline assessment of Newmont s social responsibility performance in an effort to promote continuous improvement and review best practices. The results of this assessment will be available by mid-november on the website: and will be included within the internal company performance assessments. In addition, Newmont s Ghana project was assessed in early September 2005 under the corporation s internal Five Star Management System. This is a global program which requires sites to be assessed by external assessors on their systems and performance against sets of standards in the three disciplinary areas of Environment, Health and Safety and Social Responsibility. The results of these assessments are used as the basis of continuous improvement for the sites and used for Newmont s public reports, Now & Beyond. The 2004 report for Ghana is available on the company web site and the 2005 report will be available by April These assessments will be undertaken annually and will form the basis of a continuous improvement action plan. Human Rights Beginning in November 2005, NGGL will begin to work with outside experts to investigate and benchmark human rights issues and management challenges using a variety of tools. This will be done in the first instance by a Mineral Resources Workshop from the Woodrow Wilson School at Princeton University. NGGL s Ahafo project will be a case study in a draft Human Rights Protocol for Mining Companies. Sustainable Development Foundation Newmont has committed to work with the local communities to collaboratively establish a foundation, or similar vehicle, through which the company will contribute to support specific capacity-building and infrastructure development projects. It is envisioned that the foundation development will be initiated by the beginning of 2006 with proposed operational status by yearend. It is recognized that collaboration and consensus for the foundation, consultation and establishing a governance system may take a period of time; however, the company will actively engage and promote the concept with stakeholders to encourage its expeditious formation. Newmont and the Ahafo South project will commit 1% of gross operational profit plus 1 US$ per ounce produced to fund the foundation and related development initiatives beginning in This level of funding is projected to contribute approximately US$ 650,000 per year based on current projected cash flows.

9 Social and Community Development 7 Leveraging Knowledge, Expertise and Collaborative Association The company seeks broad collaboration between the private sector, civil society and the government to leverage knowledge, opportunity, resources and expertise to multiply benefits beyond those directly associated with the company. Existing major partnerships for Ahafo include with Opportunities Industrialization Center International (a Ghanaian-US NGO of long-standing; community development); Conservation International (biodiversity and forests); University of Colorado Medical School (health baseline assessments); Planning Alliance (resettlement program); Ghana Wildlife Society (endangered species and conservation education), USAID Ghana and the International Finance Corporation (Environmental & Social Responsibility in general for the project). LIVELIHOOD ENHANCEMENT AND COMMUNITY EMPOWERMENT PROGRAM PHASE 2 NGGL s LEEP Phase 2, scheduled to commence in July 2006, commits to develop social programs and infrastructure to improve quality of life and promote community empowerment in those areas, beyond the PAP, who are experiencing secondary or indirect impacts from the development of the project. Specific areas of focus for the broader community programs in this second phase will include community health, education, infrastructure and livelihood/capacity building, developing health facilities, water, sanitation and waste management, economic and agricultural opportunities and technical training facilities. These programs will be developed in collaboration with non-governmental organizations and responsible authorities who will ultimately provide long-term management and oversight. OICI and NGGL s External Affairs team will identify recipient communities on the basis of a participatory evaluation. This evaluation will assess the level of socio-economic development using a set of criteria that measures the strengths and weaknesses of community health facilities, sanitation, waste management, water, education, and livelihood capacity/economic opportunities. In addition to LEEP 2, NGGL will work with communities and regional development planning boards in a participatory fashion to assess additional opportunities to support sustainable community development that will continue throughout the life of the mine and beyond. Agricultural Development During October 2005, Newmont began discussions with and assessing four proposals, assisted by agricultural specialists from Ghanaian company, MEL Associates and US-based Associates for Global Change. These proposals include projects to improve productivity, farm technology, crop storage and handling, distribution and access to markets. The company expects to make a decision on the nature of its involvement by mid 2006 Small-and-Medium Enterprises A robust and diverse small and medium-sized enterprise system will be established through capacity building, access to credit, and market linkages. Newmont in its Ahafo project is committed to assist in the development of local SMEs. It will document local supply and procurement capacity and build procurement linkages with local businesses as well as identify

10 Social and Community Development 8 new markets for those businesses. Working with OICI and the IFC, it will undertake an Enhanced Livelihood Capacities Program by July Water and Sanitation Newmont intends to work with local agencies to support the area with a long-term comprehensive water plan. In addition, improvement of sanitation, waste management and public facilities is an important part of the company s community development program in both LEEP 1 & LEEP 2. Employment and Training Capacity-building Increasing the skill levels and employment capacity of the Ahafo people is an objective of the company. This commitment is demonstrated in the successful establishment in 2004 of the training center at Yamfo in partnership with the National Vocational & Technical Training Institute. A similar training facility is planned for Geydu in the southern part of the mine lease with a focus on youth. Financial management seminars for locals are being held and partnerships with local universities and technical facilities are being set up. Thus far, more than 2,500 local people from the broader mine impact area have participated in the training at an estimated cost of $1.6m Going forward, operational skills will be a focus for training with a new skilled trade apprenticeship program beginning in early November. This will assist in maximizing local employment. Training of all new NGGL employees includes the company s code of business, health, safety, environmental and social responsibility. Newmont is taking part in the USAID-funded Government Accountability Improves Trust (GAIT) II project along with the District Assembly and community organizations of the Asutifi District. This project aims to build the capacity of the District Assembly and civil society organizations for better-informed participation and transparency. Employment The expected peak workforce for operations is approximately 570, comprising 40 expatriates, 180 skilled Ghanaians and 350 unskilled Ghanaians. In addition to these direct employees, the company will also hire around 350 contract service providers on a regular basis. The company, with its training programs, has implemented a wholly local hiring policy for its unskilled workforce achieving 98% for the construction phase which it intends to continue through into operation. The local workforce has deliberately been selected according to a geographically representative, community-based residence assessment, comes from the breadth and length of the mine lease area. To minimize the potentially negative social impacts of having a large group of workers residing near a community not their own, NGGL uses a fleet of more than 30 buses to take the workers to and from their homes every day. Some form of this will also be used during operations.

11 Social and Community Development 9 By year five of the operation, it is intended that national staff replace expatriate supervisors and managers at most levels and succession plans are being developed as operational recruitment builds up. Education NGGL will establish a Newmont Community Scholarship to support select students in further education. The company is also committed to improve local schools with infrastructure and facilities support. Community Health General community health indices will improve during the project life due to health education and awareness, monitoring, health care capacity improvements and optimization. In April 2005, Newmont commissioned the Colorado University School of Medicine to document and evaluate existing conditions of community health and health facilities. The findings of this study will be considered at a multi-stakeholder roundtable, facilitated by NGGL, at the end of In addition, in 2006 NGGL will collaborate with the Kintampo Health Research Centre in the Brong Ahafo region on a project to undertake a detailed baseline health survey to assess the well-being and health status of the people of the Asutifi and Tano Districts. It is likely that the recommendations of these studies will lead the company to look at strengthening of the Community-Based Health Planning and Services (CHPS) program, the upgrading of some local health facilities, the expansion of malaria interventions and a continuation of its programs to improve accessibility to clean water and adequate sanitation infrastructure. The latter initiative is supported by the on-going creation of and capacity-building for the local Water & Sanitation Committees. Another serious health risk in the area is HIV/AIDS. NGGL has a comprehensive policy which creates an HIV/AIDS program for employees including awareness raising, prevention and treatment. The company employees a full-time AIDS specialist and an HIV/AIDS steering committee has been formed. Employees have been surveyed for baseline medical information and the company will train peer counselors and community educators. Contractors are required to abide by the company s HIV/AIDS policy. Public Consultation Effective mechanisms must be established and implemented to ensure environmental and social issues are identified, discussed and resolved in collaboration with the community to achieve mutually desirable outcomes. The company s commitment to full and regular public consultation is described in the PCDP document already published. This includes continuous assessment of stakeholders, easy access to relevant information, regular release of information, clear, appropriate and consistent messages. Communication with stakeholders providing information on progress of work and ensuring awareness of special programs will take place throughout the life of the mine.

12 Social and Community Development 10 In addition, the company makes the following commitments: Meeting minutes from consultations to be submitted within seven days to project general manager Capacity-building for employees on responsibilities to external stakeholders Creation of project web site by early 2006 Transition of the Resettlement, Negotiation & Compensation Committee to a Community Liaison Committee by December 2005 Monthly meetings of the RNC/CLC Strategic communication plan for each level of government Open door policy for community workers Creation of a responsive management system for recording and responding to comments and concerns Quarterly crises communications drills Establishment of public information centers (already in several local villages) Weekly updates to information boards located in major communities Quarterly community meetings Communication capacity building Continue capacity building for local residents in conflict resolution. Communication training for the transition from RNC to CLC Establish Women's Committee in November 2005 Broaden the Newmont Rapid Response (crisis communication for stakeholders) program Grievance process Maintenance of a responsive management system for recording and responding to comments and concerns. Register all grievances, introduce open/closed status, develop criteria for grievance closure Regular meetings of relevant company staff to discuss and resolve complaints with formal responses where appropriate, within four weeks. Attitude assessment NGGL has instigated an Independent On-going Community Attitude Assessment for the Brong Ahafo region. This will be done independent of the company. This will be undertaken in November and reported on early in This is the second in a series of broad surveys of the community, its knowledge, concerns, issues and questions. Data from the first survey will be made available on the project web site in the first quarter of next year. Such surveys will be administered at least every two years. Stakeholder consultation The company is committed to ongoing stakeholder consultation throughout the life of the mine. In addition to the local consultation already detailed, NGGL will form a group of national NGO

13 Social and Community Development 11 representatives to meet quarterly for updates and discussion. Also, three meetings will be held on the project in 2006 with representatives of global NGOs. Disclosure Comprehensive documents relating to the project are available at the project public outreach office and at community and government agency locations throughout the region. These include summaries of key documents translated into Twi, the primary local language. These documents have all also been posted on the company and IFC web sites. Updates of information on the project will also be included on the project web site to be launched early in CULTURAL HERITAGE RESOURCES NGGL will develop a Cultural Resources Management Plan as an implementation of Newmont policy. This will include a survey of the community to deepen understanding of cultural resources and to enable the company to take appropriate measures for protection. Consultation on cultural property issues will also involve, where appropriate, scientific institutions and NGOs. ENVIRONMENTAL MANAGEMENT AND CLOSURE PLANNING Commitments towards environmental mitigation and enhancement, including planning towards closure, are detailed in the EIS. Environmental impact control measures, monitoring and control, and reclamation and closure activities are identified below. Similarly, NGGL is committed to actively engage community interests into post-closure land use and management planning during the early stage of the mine life. Post-closure land use and management provide potential opportunities related to land productivity and sustainability, resource management, and livelihood enhancement. It is NGGL intent to collaboratively evaluate these opportunities while ensuring long-term environmental sustainability of postclosure land conditions. Impact Control Measures Point and fugitive dust source management program to minimize dust generation and mitigate with sprays where necessary Surface water management program to control surface run-off, infiltration and ARD generation Sediment and erosion control built into environmental control measures Emergency Response Plans and systems to prevent and respond to any spills or releases of potentially contaminating substances entering surface waters All water effluent to surface water streams will meet Ghana EPA and IFC discharge standards Process facilities such as the process water pond and TSF will have appropriate liners and underdrains to collect and control any seepage Pit Lake - Site water study / water balance Fence and barrier controls to safeguard wildlife from mine facilities Complete TSF cyanide modeling and monitor during start up and stabilization of operations Cyanide in TSF will be kept below 50 ppm at all times

14 Social and Community Development 12 Implement OHS management plan Implement waste management plan Environmental Monitoring and Control Programs Air monitoring program for dust and gaseous emissions Surface water monitoring program Groundwater monitoring program which will include wells down gradient of critical facilities such as the TSF and waste rock dumps and of community boreholes and wells Monitoring program for re-vegetated areas and erosion controls, particularly after storm events Bi-annual monitoring of plant community characteristics Ongoing fauna data collection to augment baseline studies Monitoring of reclaimed areas to verify species regeneration Noxious weed / invader species monitoring and control plan Ban on hunting by all employees and contractors Partnership with Conservation International Ghana to assess biodiversity across all project related areas and to implement Biodiversity Management Plan Integrate biodiversity conservation with NGGL environmental standards and develop biodiversity indicators NGGL commit to ensure no destruction or significant conversion of critical natural habitat Integrate NGGL's EM strategies on landscape conservation Identify opportunities for off-set projects Promote biodiversity in the mining sector Minimize disturbance of natural drainages Establish fishery resources in water storage facility Implement water quality monitoring program Implement noise monitoring program Reclamation and Closure Soil will be reclaimed from all disturbed areas for future reclamation and visual impact will be minimized by reclamation of unused land. Disturbed areas will be re-vegetated concurrent with operations as soon as practical Deforestation and land clearance will be limited to the extent possible and compliant with NGGL's Biodiversity Management Plan Disturbed areas will be reclaimed (using native species) as soon as practical All surface disturbing activities in accordance with sediment control plan to minimize wetland damage. Implement and monitor hazardous materials transport, storage, use and disposal by means of Hazmat Management Plan Implementation of International Cyanide Management Code. MONITORING For environmental monitoring, NGGL is examining proposals to engage an NGO or University to provide training to local community members to either assist in or to observe formal monitoring of environmental performance and outcomes. It is envisaged that this would also involve participation of specialist scientific organizations and companies. To add another level of

15 Social and Community Development 13 assurance to this, it is planned to set up a small, imminent persons group to validate the methods and independence of the process of monitoring and testing. Monitoring and tracking of PAP, and particularly the most vulnerable people is a complex but essential task. Site personnel including the Toronto-based community resettlement and planning organization, Planning Alliance, have put together a database and the company is discussing with OICI how best to do this tracking. In October, the company met with IFC and OICI to develop a plan for a full, external monitoring and reporting program. We expect to implement this before the end of Finally, NGGL for its Ahafo project is devising a Promise Register to keep track of its commitments, both at a micro and a macro level. We will make this available to stakeholders in appropriate ways. Part of this will involve an updating of the Social Action Plan in the ESIA, updated regularly and made publicly available. RESOURCES NGGL firmly establishes its commitment to provide adequate resources to the activities and proposed benefits established in this document. It is NGGL s intent to collaborate with the community, government and other partners to maximize the effectiveness and efficiency of community development investments to ensure on-the-ground benefits for affected and nonaffected communities in the Ahafo Project area.

16 Social and Community Development 14 TABLE 2 Summary of Broader Community Commitments and Benefits Action Key Benefit Implementation Schedule Independent Assessment of Social Responsibility Performance Human Rights Baseline Sustainable Development Foundation Leverage Knowledge, Expertise and collaborative Association Livelihood Enhancement and Community Empowerment Phase 2 Public Consultation Community Attitude Assessment Cultural Heritage Environmental Management and Closure Planning Monitoring Identify weaknesses, improve performance of Community Relations and Development Benchmark Human Rights performance; promote continuous improvement Sustainable community development fund; 1% gross operational profit and 1 US$ per ounce produced Multiplier effect of community benefits from Company Agricultural production improvement practices Small and Medium Size Enterprises capacity building, linkages and sustainability Water and Sanitation Infrastructure/capacity building improvements Skill training capacity building Employment Community Education scholarships, infrastructure and facilities Community Health program Baseline Assessment Health Roundtable Household Health Survey Recommendation implementation Transition RNC to Community Liaison Committee to maintain informed about company matters, issues and listen to community concerns Independently and transparently survey community to identify concerns, issues which require company attention Document, strengthen cultural heritage of local communities Integrate post-closure land use/management opportunities into early mine life stages. Community capacity building Sept 2005; Final Report Nov 2005 Initiate Nov 2005 Initiate dialogue Jan 2006; Target startup year-end 2006 In progress Mid 2006 Scoping complete; baseline study Jan 2006; Implementation Aug 2006 Mid 2006 In progress; apprentice program Nov 2005 In progress Mid 2006 Complete Dec 2005 Jan 2006 Jan 2006 Dec 2005 Nov 2005; update on two year cycle Establish participatory monitoring body, protocols Identify independent body to validate monitoring and results